DRENNEN, Judge:
The Commissioner caused a notice of liability to be issued to petitioner in which a liability of $14,317.83 plus interest was determined for assessment against petitioner, which amount was alleged to be petitioner's liability as a fiduciary for U.S. estate tax due from the Estate of Louis Rotenberg (hereinafter called the estate). It has been stipulated that since petitioner has paid over to respondent all amounts accruing to the estate from...
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